United States v. Ogembe, 41 F.Supp.2d 567
(E.D.Pa. Mar. 3, 1999) (federal conviction of conspiracy to
commit bank fraud in violation of 18 U.S.C. § 371 constitutes
an aggravated felony as an offense that "involves fraud
or deceit in which the loss to the victim or victims exceeds
$10,000" under INA §§ 101(a)(43)(M)(i), (U), 8 U.S.C.
§§ 1101(a)(43)(M)(i), (U), regardless of sentence).